IR 05000298/1989001
| ML20246N296 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/01/1989 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8905190399 | |
| Download: ML20246N296 (1) | |
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i In Reply Refer To:
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Nebraska Public Power District ATTN: George A. Trevors Division Manager - Nuclear Support P.O. Box 499 Columbus, NE 68602-0499 Gentlemen:
Thank'you' for your letter of April 3,1989, in response to our letter and inspection report dated February 27, 1989. We have reviewed your reply and find it responsive to the concerns raised in our inspection report. We will review the implementation of your corrective actions during a future inspection.
Sincerely,
' Original Sigacd By:
C.J. CALLAN L. J. Callan, Director Division of Reactor Projects cc:
Cooper Nuclear Station ATTN: Guy Horn, D1 vision Manager of Nuclear Operetions P.O. Box 98 Brownville, Nebraska 68321
. Kansas Radiation Control Program Director Nebraska Radiation Control Program Director bectoDMB(IE01)w/licenseeltr.
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i U.S. Nuclear Regulatory Commission i
Attn: Document Control Desk O
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Subject: Response to IE Inspection Report No. 50-298/89-01 Cooper Nuclear Station NRC Docket No. 50-298, DPR-46 i
Gentlemen:
This letter is in response to your letter dated February 27, 1989, which transmitted IE Inspection Report No. 50-298/89-01. Therein, you indicated that certain of our activities appeared to deviate from commitments made to the NRC.
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Following is the statement of the deviation and the District's response:
STATEMENT OF DEVIATION Failure To Seal Or Lock Instrument Valves Updated Safety Analysis Report (USAR)Section VII.2.5, "Inepection and Testing," prescribes a procedure for conducting calibration tests of reactor protection system channels. This procedure delineates the operation of instruments used for sensing reactor pressure and reactor water level the USAR states, in part, "The test is conducted as follows:
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An instrument technician following instructions of authorized personnel unlocks or cuts the seal on instrument shutoff valves to a specific in-e ument and shuts off the instrument line....
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'd.s calibration signal is then reduced to zero, the test is removed, the calibration taps plugged, the sensors valved into service, and the valves sealed or locked in their operating positions."
In deviation from the above, the instrument shutoff valves for sensing reactor pressure and reactor water level were not sealed or locked as committed to in the USAR.
(298/8901-01)(Supplement I).
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REASON FOR THE DEVIATION The Dietrict agrees that the instrument shutoff valves for sensing. reactor pressure and reactor water level for the Reactor Protection System (RPS) were not sealed or locked as described in the USAR. The above noted statement in the USAR was contained in the Final Safety Analysis Report (FSAR) that was submitted to the Atomic Energy Commission for review on February 26, 1971.
During plant construction and startup it was determined that the use of detailed procedural controls and the training of operators and technicians met the intent of ensuring these valves were maintained in their proper position and that locking devices were not needed nor desired.
Subsequent plant operation in the intervening years with no instance of these valves being found in an incorrect position has substantiated this methodology as an effective method'of control.
The reason for this deviation is that the FSAR and, more recently, the USAR were not revised to reflect the implemented method of valve control for instrument shutoff valves pertaining to the reactor protection syatem.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A request has been initiated to the Nuclear Licensing and Safety Department to revise the applicable pages of the USAR and delete reference to seals or locking devices on shutoff valves to the instruments sensing reactor pressure and reactor water level for the Reactor Protection System.
A review of other valve manipulations as described in the USAR for the testing of reactor pressure and water level sensors for RPS has been performed to determine if other deviations existed. None were identified. Additionally, Surveillance Procedures 6.1.5, "RPS High Reactor Pressure Calibration And Functional / Functional Test", and 6.1.9, " Reactor Vessel Low-High Water Level Calibration And Functional / Functional Test", were reviewed to verify that they contain adequate controls to ensure instruments are properly returned to service.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUTURE DEVIATIONS The CNS USAR will be revised to delete mention of locking (evices or seals on the applicable instrument shutoff valves. This change will be incorporated into the next revision of the USAR which will be submitted per 10CFR50.71 on or before July 22, 1989.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The CNS USAR will be revised on or before July 22, 1989, and will include the deletion of locking devices or seals on the applicable instrumentation.
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',U.S. Nucleer Ragulatory Commission
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March 27, 1989
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Should you have any questions concerning this matter, please contact my office..
Sincerely,
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Division Manager Nuclear Support GAT /GRS/jer cc: N.S. Nuclear Regulatory Commission Regional Office, Region IV Arlington, TX hTC Resident Inspector Cooper Nuclear Station
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